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 Post subject: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 12:04 am 

Joined: Tue Nov 12, 2013 6:45 pm
Posts: 257
Could someone please point me to the FRA regulation that bans paint on couplers? I'm looking for the specific language of the rule and any exemptions. I looked at part 231 of the CFRs, but I didn't see anything that specifically bans paint on couplers.

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 7:47 am 

Joined: Fri Aug 27, 2004 9:19 am
Posts: 563
Location: Scottsboro, AL
The prohibition appears in the AAR Field Manual of Interchange Rules; Rule 16, Section E, item 4: "Coupler bodies must not be painted."

FRA regulations of couplers and draft systems appear in section 215. Although not specifically mentioned; paint would interfere with inspection for cracks, therefore it would be reasonable to assume that FRA would take exception on that basis.

Alan Maples


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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 8:51 am 

Joined: Tue Sep 14, 2004 7:52 am
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Location: Strasburg, PA
That was always something that I have been curious about as well, since it seems like the majority of couplers on steam locomotives are painted. Being that it is an AAR rule specifically may explain it since steam locomotives were not interchanged on any regular basis, though I wonder if that is a more recent rule, since when watching color films of old railroad operations, it seems that painted couplers were a regular sight on all types of equipment back in the day.

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 10:25 am 

Joined: Sun Aug 22, 2004 1:51 pm
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Location: Somewhere north of Prescott, AZ on the Santa Fe "Peavine"
Kelly Anderson wrote:
That was always something that I have been curious about as well, since it seems like the majority of couplers on steam locomotives are painted. Being that it is an AAR rule specifically may explain it since steam locomotives were not interchanged on any regular basis, though I wonder if that is a more recent rule, since when watching color films of old railroad operations, it seems that painted couplers were a regular sight on all types of equipment back in the day.


Just last night I saw a "slide show" of a variety of D&H equipment during the 1970s, and the heyday of their Alco PAs and Baldwin Sharks, in which several shots showed overzealous painters had covered the entire pilots, including the couplers and knuckles, with paint prior to special excursions or even regular passenger or freight service.


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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 5:24 pm 

Joined: Tue Nov 12, 2013 6:45 pm
Posts: 257
Alan Maples wrote:
The prohibition appears in the AAR Field Manual of Interchange Rules; Rule 16, Section E, item 4: "Coupler bodies must not be painted."

FRA regulations of couplers and draft systems appear in section 215. Although not specifically mentioned; paint would interfere with inspection for cracks, therefore it would be reasonable to assume that FRA would take exception on that basis.

Alan Maples


If it is just AAR rule, they why am I be hearing that the FRA would cite me for paint on a coupler? I looked through part 215's section on couplers and didn't see anything outlawing paint.

As information, the basis of my question lies in former Milwaukee Road Dynamometer X-5000; the front coupler and knuckle of which has the top painted white. Well, it was painted white; like the rest of car's paint, its badly faded and chipped.

You can see what I mean in these photos from back in the day:

http://www.rrpicturearchives.net/showPi ... id=1873222

and

http://www.rrpicturearchives.net/showPi ... ?id=343259

When the time comes to paint the car, we will have to decide about putting fresh paint on the coupler or not. I was hoping to find the concrete parameters for putting any paint on a coupler.

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 5:40 pm 

Joined: Sun Aug 22, 2004 9:54 am
Posts: 845
Location: NJ
Didn't they used to whitewash steam locomotive side rods to detect cracks, many years ago? Perhaps MILW was using that kind of thinking on the dynamometer car, that whitewash would show a crack? In service, one of that car's couplers and the rear locomotive coupler would have the most strain. Also, interchange rules most likely would not apply, as I'm sure a dyno car is usually captive. Just my 2 cents-


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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 6:00 pm 

Joined: Tue Nov 12, 2013 6:45 pm
Posts: 257
The paint was added after they added a camera looking down at the front coupler to monitor slack action; I'm not positive what was being tested at the time (Stepless throttle, Locotrol, and train-handling trials among other possibilities). They apparently decided it would be easier to pick out which coupler was the dynamometer's if the top of it was white.

The most strained coupler on the car would be this one, the one with paint, as it is on the instrument end of the car where the dynamometer itself is spliced into the draft gear. While it is physically possible (and has been done at IRM) to run the car with the kitchen end leading, the Milwaukee is not known to have done that. The only time a locomotive would have been coupled to the rear coupler in service would have been during testing of Locotrol; during which it was cut in between the front section of the train and the (Locotrol) helpers.

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 6:10 pm 

Joined: Fri Dec 03, 2004 9:42 pm
Posts: 2552
Bulby wrote:
The paint was added after they added a camera looking down at the front coupler to monitor slack action; I'm not positive what was being tested at the time (Stepless throttle, Locotrol, and train-handling trials among other possibilities). They apparently decided it would be easier to pick out which coupler was the dynamometer's if the top of it was white.


I'm not sure why it would matter which coupler was which? What would that information add to the test films?

On the other hand, I could see it being done to increase the contrast between the two couplers, on white, one gray, black, rust brown, etc. Having two contrasting colors would aid in seeing when there was slack and when there wasn't.

I recall when MRSR first brought our Shay online. She was being used as a helper on the Santa train, which had one engine on each end for quick and easy directional change at the endpoints.

I'm standing on the back platform of the caboose and looking down. "Hey, you're not pushing!" "Yes I am..." "Nope, we're dragging you" (Chugging gets louder...) "More!" (Louder...) "More!" (Still louder) "OK, now there's slack..." We were amazed at how much steam a Shay needed to roll down the track, even under light load.

That engineer later quipped "Grrr... She'd use 10 pounds of steam falling down a well!"


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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 6:12 pm 

Joined: Thu Aug 26, 2004 2:50 pm
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Location: Northern Illinois
They undoubtedly wanted to correlate whether the locomotive was actually pulling the train or not with their instrumentation. I recall an article in Trains magazine long ago where the author recounts walking the top of the train, back and forth, while doing a study on helper usage. He needed to confirm how many cars the helper was actually pushing, so needed to keep track of the slack.

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 6:53 pm 

Joined: Fri Dec 03, 2004 9:42 pm
Posts: 2552
Dennis Storzek wrote:
They undoubtedly wanted to correlate whether the locomotive was actually pulling the train or not with their instrumentation. I recall an article in Trains magazine long ago where the author recounts walking the top of the train, back and forth, while doing a study on helper usage. He needed to confirm how many cars the helper was actually pushing, so needed to keep track of the slack.


Yes, obviously. But my question is, when you're looking at whether the couplers are slack or tight, does it matter at all which coupler is attached to the locomotive and which is attached to the dyno car? Either there is slack or there is not. I don't see where identifying which coupler is connected to which piece of equipment changes that in any manner. So why paint one white to distinguish them? What have I overlooked? (My theory is that they did it to make more contrast for the photos, not that it makes much of any difference...)


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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Tue May 13, 2014 9:04 pm 

Joined: Fri Aug 27, 2004 9:19 am
Posts: 563
Location: Scottsboro, AL
Bulby wrote:
Alan Maples wrote:
The prohibition appears in the AAR Field Manual of Interchange Rules; Rule 16, Section E, item 4: "Coupler bodies must not be painted."

FRA regulations of couplers and draft systems appear in section 215. Although not specifically mentioned; paint would interfere with inspection for cracks, therefore it would be reasonable to assume that FRA would take exception on that basis.

Alan Maples


If it is just AAR rule, they why am I be hearing that the FRA would cite me for paint on a coupler? I looked through part 215's section on couplers and didn't see anything outlawing paint.

. . .

I was hoping to find the concrete parameters for putting any paint on a coupler.


You will not find "concrete parameters" in the federal regulations. However the regulations do specify the areas where cracks would be considered a defect. Your best bet is to consult with your local MP&E inspector. Where the AAR rules are more restrictive they are generally not subject to FRA enforcement action. Since a painted coupler would be an anomaly it is likely to call attention to itself, but in a museum environment it is unlikely to be a problem.

Alan Maples


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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Wed May 14, 2014 12:07 am 

Joined: Sun Aug 22, 2004 8:35 pm
Posts: 374
Union Pacific had a Dyno car that we (Wasatch Railroad) actually considered purchasing. What we found interesting about the car was the fact that the strain gauge end had cushioned draft gear. Generally a locomotive attached to a dyno car has rigid or fixed or non-cushioned draft gear.....what ever term you want to use.

The strain gauge measured the draft forces based on the motion of the cushioned draft gear on the car, pulling or drifting. I can see how a camera could be used to measure specific locations of the coupler in a pulling or drifting mode and therefore could generate some specific information related to strain.....makes sense. Painting the coupler top white would accentuate the picture and make the measurement easier.

Note that FRA has not enforced the painted coupler deal much beyond the past ten years. In fact, if you look at enough Private Car photos and painted locomotives (mostly Bicentennial locomotives of 1976) you will find a number of painted couplers. Go dig through a stack of old UP Calendars from the 70's and 80's.....SD-40's all had gray painted couplers, air hoses and pilots.

Here is the funny part......Go buy a can of flat brown spray paint and paint the top of your coupler brown and then mix in some flat black over coat and some touches of flat gray. Then, go find an MP&E to inspect the item. 9 out of 10 inspectors will miss the paint on the coupler as it looks too natural. BUT......paint it WHITE and the gods of railroading will come down hard on you.....paint it anything other than a natural color.....watch out.

Why? It looks like you are intentionally trying to hide something. Most MP&E classes teach inspectors to watch for things that may indicate an issue.....covering a crack on a coupler with white paint is a dead giveaway to a problem with the coupler......BUT.....painting it natural brown and adding hints of gray and black won't single an issue at all. I speak from year of experience! I am more than happy to lay out a list of locomotives I have painted couplers flat brown just to get them past FRA and to date, have not been caught yet!

Odd right? This whole thing is a culture issue.....not really a hard and fast rule.

If it is an FRA MP&E who is hassling you.....have HIM show you the hard and fast rule!!!! If he can't; ask him to call his regional administrator and ask him where it is in the 49CFR.....and if that doesn't work, have the regional admin call DC......now you will get action!!!!!

Kindly,

JohnE.

P.S. Write a waiver request (except that you don't have a rule to waive) and call it a "special service/dedicated service coupler". After all it was a "company car" specific service car.

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Wed May 14, 2014 2:58 pm 

Joined: Sun Aug 22, 2004 1:18 am
Posts: 120
Location: B'more MD
I agree with what John R. has said. I always have found that politely asking for the exact citation, in order to "completely understand what you must do to meet the regulation", is always a prudent action. I know some of the FRA MPE types lurk on this board. Perhaps we'll here from them, or get some additional clarification through an intermediary. I did a quick search of the FRA Compliance Manual, available on line, and could not find any references to painted couplers, although there are mentions of inspecting couplers.

As somebody else said, anything hindering inspections would be frowned upon, and it is an AAR rule. More than one FRA field guy has tried to enforce AAR rules. Once I had an FRA Associate Administrator of Safety offer to send a level headed inspector out to help me. Then he realized exactly what he had said, and quickly amended his statement to the effect that all of his inspectors were level headed, just some were more level headed than others. Good luck.


G.F.Payne
Baltimore, MD

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 Post subject: Re: Looking for Federal Regulations citation
PostPosted: Wed May 14, 2014 5:38 pm 

Joined: Wed Oct 13, 2004 12:56 am
Posts: 382
Location: Northern California
I believe the reason the AAR does not want couplers painted is so the paint does not gum up the works. More a problem for top operated couplers than bottom operated couplers. This is the same reason the AAR does not allow lubrication of couplers. The locking mechanism is actually fairly delicate so it can distinguish between the operation of the cut lever by a person from operation of the cut lever from impact switching.

Cracks in couplers are not real common. If the coupler leaves the factory in good shape, it will not develop a crack except through sever abuse. This is in contrast to wheels, which have the thermal abuse from braking problems, and axles, which see cyclic loads leading to fatigue failures. Inspection and detection of cracks in this equipment warrants the no paint rule.

MP and E inspectors inforcing imaginary rules is always a problem. If you run in to this, a letter to Washington is in order requesting a clarification. FRA management needs to know what is going on in the field.

Painting the top of a knuckle white so it can be seen by a TV camera is an interesting detail and should be preserved. I hope the FRA or their self appointed assistants do not deter the preservation of this unique feature.


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